Author : A.M. Chowdhary
Publisher :
Page : pages
File Size : 26,57 MB
Release : 2021
Category :
ISBN :
In this article, the author considers the role of the U.N. Committee of Experts on International Cooperation in Tax Matters and how it can be improved.
Author : Department of Economic & Social Affairs
Publisher : United Nations Publications
Page : 295 pages
File Size : 49,35 MB
Release : 2008
Category : Business & Economics
ISBN : 9789211045871
This book presents an overview of the key debates that took place during the Economic and Social Council meetings at the 2007 High-level Segment, at which ECOSOC organized its first biennial Development Cooperation Forum. The discussions also revolved around the theme of the second Annual Ministerial Review, "Implementing the internationally agreed goals and commitments in regard to sustainable development."--P. 4 of cover.
Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
Page : 86 pages
File Size : 28,94 MB
Release : 2011-08-03
Category : Business & Economics
ISBN : 1498339247
The Fund has long played a lead role in supporting developing countries’ efforts to improve their revenue mobilization. This paper draws on that experience to review issues and good practice, and to assess prospects in this key area.
Author : Martin Hearson
Publisher : Cornell University Press
Page : 162 pages
File Size : 26,3 MB
Release : 2021-06-15
Category : Business & Economics
ISBN : 1501755994
In Imposing Standards, Martin Hearson shifts the focus of political rhetoric regarding international tax rules from tax havens and the Global North to the damaging impact of this regime on the Global South. Even when not exploited by tax dodgers, international tax standards place severe limits on the ability of developing countries to tax businesses, denying the Global South access to much-needed revenue. The international rules that allow tax avoidance by multinational corporations have dominated political debate about international tax in the United States and Europe, especially since the global financial crisis of 2007–2008. Hearson asks how developing countries willingly gave up their right to tax foreign companies, charting their assimilation into an OECD-led regime from the days of early independence to the present day. Based on interviews with treaty negotiators, policymakers and lobbyists, as well as observation at intergovernmental meetings, archival research, and fieldwork in Africa and Asia, Imposing Standards shows that capacity constraints and imperfect negotiation strategies in developing countries were exploited by capital-exporting states, shielding multinationals from taxation and depriving nations in the Global South of revenue they both need and deserve. Thanks to generous funding from the Gates Foundation, the ebook editions of this book are available as Open Access volumes from Cornell Open (cornellpress.cornell.edu/cornell-open) and other repositories.
Author : Christian Knotzer
Publisher : Kluwer Law International B.V.
Page : 551 pages
File Size : 43,84 MB
Release : 2024-07-15
Category : Law
ISBN : 940352488X
This groundbreaking book – a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy – provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for ‘Income from Automated Digital Services’. In extensive detail, the author thoroughly examines the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author’s analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book’s clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.
Author :
Publisher :
Page : 400 pages
File Size : 29,74 MB
Release : 1990
Category : Australia
ISBN : 9780195531916
Author : United Nations Publications
Publisher :
Page : 0 pages
File Size : 24,3 MB
Release : 1984-12-31
Category :
ISBN : 9780119083200
Author : United Nations
Publisher :
Page : 672 pages
File Size : 23,92 MB
Release : 2017
Category : Business & Economics
ISBN :
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
Author : Great Britain: Parliament: House of Commons: International Development Committee
Publisher : The Stationery Office
Page : 168 pages
File Size : 46,75 MB
Release : 2012-08-23
Category : Business & Economics
ISBN : 9780215047533
This report highlights the importance of tax collection in developing countries, and recommends that the UK's aid programme should increase its focus on supporting tax authorities. This is equally valid for all forms of taxation, including VAT, personal income taxation and corporate taxation. It is also essential that taxes are paid on a fair and equal basis by all. New tax rules on developing countries, the Controlled Foreign Companies (CFC) rules are designed to discourage UK-owned corporations from using tax havens. Traditionally these rules have applied to all UK-owned corporations - both those operating in the UK and those operating overseas. Under the new rules, however, this will apply only to corporations operating in the UK, making it easier for those operating in developing countries to use tax havens. A number of NGOs have campaigned vigorously against the changes, with ActionAid estimating that developing countries may lose up to £4 billion in tax revenues as a result. The UK Government does not accept this estimate, but does not deny that there will be some cost to developing countries. The Committee recommends that - subject to the outcome of its own analysis - the Government should consider reversing the change as a matter of urgency. The Committee also received evidence which argued that the Government should require UK-owned companies to report their financial information on a country-by-country basis, rather than on an aggregate basis. The Government is reluctant to act unless other EU countries do likewise, but the Committee believes that it should act unilaterally
Author : Anna Binder
Publisher : Linde Verlag GmbH
Page : 664 pages
File Size : 15,49 MB
Release : 2019-10-01
Category : Law
ISBN : 3709410398
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.
